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FOCUS HR  |  IR July Update 2026
FOCUS HR  |  IR July Update 2026
PAYDAY SUPERANNUATION
BABY PRIYA’S ACT 2025 
PROTECTING PENALTY & 
OVERTIME RATES ACT 2025
When – 1 July 2026 
The Treasury Laws Amendment (Payday 
Superannuation) Act 2025 and Superannuation 
Guarantee Charge Amendment Act 2025 were 
introduced into Parliament on 9 October 2025.
From July 2026 employers will generally be required 
to make superannuation contributions within seven 
business days of paying employees’ wages and salaries 
rather than quarterly.
The reforms introduce a new concept called “qualifying 
earnings” (QE), which will be used to calculate 
both superannuation guarantee contributions and 
superannuation guarantee charge calculations.
Qualifying earnings consist of:
•	 ordinary time earnings;
•	amounts of ordinary time earnings sacrificed under 
salary sacrifice arrangements; and
•	certain payments captured within the extended 
meaning of employee under the Superannuation 
Guarantee legislation.
The Australian Taxation Office has also published 
a draft compliance guidance regarding its intended 
approach during the first year of Payday Super.
When – 7 November 2025 
The Fair Work Amendment (Baby Priya’s) Act 2025 
introduced new protections for employees who 
experience the stillbirth or death of a child and are 
entitled to employer-funded paid parental leave. 
The reforms were introduced following a widely 
publicised campaign that highlighted a gap in the 
Fair Work Act where employees could retain access 
to unpaid parental leave and government-funded 
parental leave, but could lose access to employer-
funded paid parental leave following the death of a 
child.
The legislation is named after Baby Priya, who tragically 
died at 42 days old. Following her death, her mother’s 
employer-funded paid parental leave was cancelled, 
prompting calls for legislative reform to ensure grieving 
parents did not face uncertainty regarding their leave 
entitlements during an already traumatic period.
The reforms insert a new workplace protection into 
the Fair Work Act preventing employers from refusing 
or cancelling employer-funded paid parental leave 
because an employee’s child is stillborn or dies, where 
the employee would otherwise have been entitled 
to that leave under their terms and conditions of 
employment.
The protections apply to employer-funded paid 
parental leave associated with:
•	the birth of an employee’s child;
•	the birth of a child of an employee’s spouse or de 
facto partner; or
•	the placement of a child with an employee for 
adoption.
Importantly, the legislation does not create a new 
entitlement to employer-funded paid parental leave. 
Rather, it preserves existing entitlements that arise 
under employment contracts, enterprise agreements, 
workplace policies or other employment arrangements.
The reforms also recognise that employers and 
employees may have existing arrangements dealing 
with stillbirth or the death of a child. Certain exceptions 
apply where employment terms expressly provide 
for different arrangements. However, employers 
cannot unilaterally amend employment terms after 
commencement of the legislation in order to avoid the 
operation of the new protections.
The protections commenced on 7 November 2025 and 
apply where the stillbirth or death of a child occurs on 
or after that date.
When – 30 August 2025 
The Fair Work Amendment (Protecting Penalty and 
Overtime Rates) Act 2025 received Royal Assent on 
29 August 2025 and commenced on 30 August 2025.
The legislation restricts the Fair Work Commission’s 
ability to reduce or roll up overtime and penalty rate 
entitlements into annualised salary arrangements.
The reforms require the Commission to ensure:
•	specific penalty and overtime rates in modern Awards 
cannot be reduced; and
•	modern awards cannot include rolled-up salary 
arrangements which do not fairly compensate award-
reliant employees for the penalty rates and overtime 
they would have otherwise received. 
Practical Implications  
for Employers
Employers should review:
•	payroll systems and automation capability
•	payroll reconciliation processes
•	salary sacrifice arrangements
•	payroll timing and cashflow forecasting and
•	superannuation reporting systems
Practical Implications  
for Employers
Employers should:
•	review annualised salary arrangements to 
ensure employees remain no worse off than 
if they were paid in accordance with Award 
terms
•	reassess salary absorption or offset clauses
•	ensure overtime and penalty entitlements 
are reconciled accurately (this includes 
appropriate record keeping) and
•	review payroll compliance processes
Practical Implications  
for Employers
Employers should consider:
•	reviewing company-paid parental leave 
entitlements in policies, employment contracts 
or enterprise agreements with the lens that 
these now cannot be removed in the case of 
stillbirth or death of a child
•	ensuring managers understand the new 
protections
•	reviewing workplace processes for handling 
parental leave following stillbirth or infant 
death; and
•	ensuring any decisions regarding parental 
leave entitlements are consistent with the 
amended Fair Work Act.
Observation
The reforms reinforce the broader movement 
toward real-time payroll compliance and increase 
administrative and payroll compliance obligations for 
employers.
Observation
The legislation reflects increasing political and 
regulatory concern regarding annualised salary 
arrangements and payroll compliance transparency. 
It does not stop employers and employees from 
entering into annualised salary or individual flexibility 
arrangements under the Award, but it does add a 
layer of protection to prevent terms that would leave 
employees worse off.
Observation
The reforms reflect an increasing focus on aligning 
workplace laws with community expectations 
regarding compassion, psychological wellbeing and 
employee support during significant life events. 
Baby Priya’s Act also demonstrates the growing 
willingness of Parliament to intervene where gaps 
emerge between statutory leave protections and 
employer-funded workplace entitlements.

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